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petition in this case, petitioner made statements and requests
and advanced contentions and arguments that the Court has found
to be frivolous and/or groundless. In that petition and the
supplement thereto, petitioner persists in advancing such frivo-
lous and/or groundless statements, requests, contentions, and
arguments. Consequently, even though we held in Keene v. Commis-
sioner, 121 T.C. 8, 19 (2003), that section 7521(a)(1) requires
the Appeals Office to allow a taxpayer to make an audio recording
of an Appeals Office hearing held pursuant to section 6330(b), we
conclude that (1) it is not necessary and will not be productive
to remand this case to the Appeals Office for another hearing
under sections 6320(b) and 6330(b) in order to allow petitioner
to make such an audio recording, see Lunsford v. Commissioner,
117 T.C. 183, 189 (2001), and (2) it is not necessary or appro-
priate to reject respondent’s determinations to proceed with the
collection action as determined in the notice of determination
and in the decision letter with respect to petitioner’s unpaid
liability for 1994, petitioner’s unpaid liability for 1996, and
petitioner’s respective unpaid liabilities for 1998 and 1999, see
id.9
Based upon our examination of the entire record before us,
8(...continued)
to respondent his request to make an audio recording of his
hearing with the Appeals Office in advance of that hearing.
9See Kemper v. Commissioner, T.C. Memo. 2003-195.
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